SIA Solfegio (“Solfeg.io”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through websites operated by us from which you are accessing this Privacy Policy (the “Website”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), and through HTML-formatted email messages that we send that link to this Privacy Policy (collectively, including the Websites and Apps, the “Services”). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

Last updated: May 24, 2018

What is Solfeg.io?

Solfeg.io provides a music education software that can be used through most web browsers (at http://web.solfeg.io) and through our Apps. A Solfeg.io web software (referred to as a “Solfeg.io”) consists of songs that users can learn to play together in the classroom and at home.

Personal information

“Personal Information” is information that identifies an individual or relates to an identifiable person, including:

Your teaching level, if you are a teacher (such as kindergarten, grade level, higher education, etc.)

We may need to collect and process Personal Information marked as ‘required’ in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Personal Information We May Collect

We do not collect any Personal Information from a person who merely visits Solfeg.io website. In order to be able to see and play songs, however, a user (“accountholder”) must create an account at

http://web.solfeg.io/ or through our App. As described in more detail below, we may collect and use Personal Information from adult accountholders. An “adult accountholder” is a U.S. user who is age 13 or older or a user from outside the U.S. who is age 16 or older.

Our information practices are different with respect to younger users. Specifically, when a U.S. user who is under the age of 13 or a user from outside the U.S. who is under the age of 16 creates an account (a “child accountholder”), we collect his or her email address only for the purpose of providing password reminders to him or her. We collect no other Personal Information from child accountholders, and we immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child accountholder.

How We May Collect Personal Information

We and our service providers may collect Personal Information from adult accountholders in a variety of ways, including:

Through the Services: We may collect Personal Information through the Services, e.g., when you create an account, register your credit/debit card information and other financial data that we/our payment processors need to provide the Services, or populate your profile.

Offline: We may collect Personal Information from you offline, such as when you contact customer service.

From Other Sources: We may receive your Personal Information from other sources, such as Facebook (if you choose to register using your Facebook account), public databases, joint marketing partners and other third parties.

How We May Use Personal Information

We and our service providers may use Personal Information for our legitimate business interests, including the following:

To respond to your inquiries and fulfill your requests, such as to send you newsletters.

To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.

To send you marketing communications that we believe may be of interest to you, such as recommended songs based on your general location and your use of the Services, subject to your consent if required by applicable law.

To personalize your experience on the Services by presenting songs and offers tailored to you.

To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully.

To allow you to share songs and initiate challenges through the Services, and to notify you when a song is shared with you, when a challenge you have created is featured to others on the Services, or when you have been invited to join a challenge.

For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

To process your payments for the Services.

How Personal Information May Be Disclosed

The Personal Information of adult accountholders may be disclosed:

To our third party service providers who provide services such as website hosting, information technology and related infrastructure provision, customer service, email delivery, auditing, payment processing and other services.

To identify you to anyone with whom you share songs or other messages, including challenges, through the Services.

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

Browser and device information

App usage data

Information collected through cookies, pixel tags and other technologies

Demographic information and other information provided by you

Aggregated information

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.

Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information has been downloaded to the App based on your device number.

Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information only to support the internal operations of the Services, such as for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.

Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including adult accountholders that may receive emails from us), measure the success of marketing campaigns and compile statistics about usage of the Services and response rates.

Analytics: We use third parties, including Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for the purposes of providing support for the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate, general, location from your IP address.

From you: Information such as communications preference may be collected from adult accountholders when they voluntarily provide it.

By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services.

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

OUR COLLECTION OF PERSONAL INFORMATION FROM CHILDREN

As explained above, we do not collect any Personal Information from a person who merely visits Solfeg.io website.

When a user who is under the age of 13 (for U.S. users) or 16 (for non-U.S. users) creates an account (a “child accountholder”), we collect his or her email address only for the purpose of providing password reminders to him or her. We immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child accountholder.

We also collect a user name and password from child accountholders, which are used for login purposes only, to permit the child accountholder to use the Services.

We and our service providers also collect the information described above, under “Other Information,” from child accountholders. This includes Google’s use of certain persistent identifiers to collect information about the use of our Services for analytics purposes only.

If you would like to review the information we have collected from your child (i.e., his or her username and password), or if you would like to ask us to make no further use of, or delete, the information we have collected from your child, contact us using the live chat provided it the website. In your request, please include your name and your child’s Solfeg.io username, and specify the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

We give adult accountholders choices regarding our use and disclosure of their Personal Information for marketing purposes. You may opt-out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email. In addition, in your user settings, you may opt-out of receiving emails letting you know that a challange has been shared.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or suppress your Personal Information

If you are an adult accountholder and you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, restrict the processing of your Personal Information, object to the processing of your Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in live chat service in our website.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. You may also delete your account by sending us a request in the live chat widget when logged into the Services. You may also delete, when logged into the Services, any content or information that you have posted to the Services in the form of challenges that you have created. Please note that your actions cannot ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted or repurposed by another accountholder. We will try to comply with your requests as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

Retention period

We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you and provide our Services to you; (ii) as required by a legal obligation to which we are subject to; (iii) or as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

Cross-border transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country.

If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us (see below under Contacting Us).

Sensitive information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

Updates to this Privacy Policy

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at

info@solfeg.io or

Solfeg.io

Elizabetes 45/47

Riga, LV1010

Latvia

Because email communications are not always secure, please do not include sensitive information in your emails to us.